Compliance

Material Topic: Compliance

2-27 Compliance with laws and regulations

JSR is committed to compliance with all environmental laws and regulations. As evidenced throughout this report, this reporting period was unique as COVID-19 created atypical circumstances requiring prompt changes to normal business practices. Although JSR made every effort to continue compliance with environmental regulations throughout the reporting period, a single lapse in compliance occurred as an unforeseeable consequence of COVID-19-related health and safety measures.

JSR received a Notice of Violation (NOV) in February of 2021 from the Bay Area Air Quality Management District (BAAQMD). The NOV was a consequence of procedural changes due to COVID-19, which was quickly resolved and JSR did not contest the resulting $5,000 fine.

As required by the BAAQMD issued air permit, JSR uses a handheld photoionization detector (PID) to measure volatile organic compound (VOC) emissions of its carbon abatement system on a weekly basis. The contractor who typically performs on-site PID calibration requested that the device be sent for off-site calibration due to COVID-19 safety concerns. The NOV was issued because JSR did not obtain a rental unit while its PID was being calibrated off-site.

The off-site calibration resulted in a brief, unintentional interruption in measurements. An internal investigation revealed that there were no excess site emissions during the off-site calibration. Until this incident, JSR had not missed weekly calibrations for nearly a decade. No other compliance violations occurred during the reporting period. JSR takes environmental responsibility seriously and has adjusted protocols to ensure that this does not recur in the future.

205-1 Operations assessed for risks related to corruption

All JSR business entities are required to perform an annual compliance review, which assesses the risks related to corruption, as well as risks of non-compliance with other applicable laws. These applicable laws include, but are not limited to, the US Foreign Corrupt Practices Act (FCPA) and the UK Anti-Bribery Act.

205-2 Communication and training about anti-corruption policies and procedures

JSR’s compliance policy is defined by Compliance with Laws and The JSR Group Principles of Corporate Ethics – Corporate Code of Conduct. Both of these documents are available to employees on the InsideJSR intranet. Training is also offered to employees on certain high-risk topics. During the reporting period, training was provided regarding compliance risks involving Antitrust and Foreign Investment (CFIUS) regulations in merger and acquisition transactions.

205-3 Confirmed incidents of corruption and actions taken

There have been no confirmed incidents of corruption.

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services

During the reporting period, JSR was not cited for any concerns regarding the health and safety impacts of its products.

417-2 Incidents of non-compliance concerning product and service information and labeling

During the reporting period, JSR was not cited for any concerns regarding product information or labeling.